Video captioning and accessibility regulations

WCAG success criteria 1.2.2 requires that captions are provided for all pre-recorded audio content in synchronized media, except when the media is a media alternative for text and is clearly labelled as such. 

There is a failure of success criteria 1.2.2

"If the "caption" does not include all of the dialogue (either verbatim or in essence) as well as all important sounds then the 'captions' are not real captions."

Additionally, W3C says that automatic captions are not sufficient.

"automatically-generated captions do not meet user needs or accessibility requirements, unless they are confirmed to be fully accurate. Usually they need significant editing." 

Who is responsible?

The responsibility under PSBAR lies with the public sector body as a whole. In effect, this is the senior responsible officer, or the executive team. This is why leadership buy-in and a cross-organisational approach is so important when implementing accessibility.

A process like captioning, that requires time and resourcing, needs leadership and management buy-in to make it happen.  If you require support from the us on strategic approaches to advancing accessibility, contact your relationship manager to arrange a chat or to find out about services.

The challenge for colleges and universities

Ensuring that all audio and video recordings are accessible to the required standard presents challenges for institutions.

For many colleges and universities, checking and correcting for full accuracy on all video is not something they will be able to easily achieve, particularly given the volume of video still being produced since the large-scale move online in 2020.

What you can do

Be transparent in accessibility statements

Colleges and universities have been working hard to ensure online content is accessible during an extremely challenging time. As organisations continue to improve the process of video captioning, it is important to recognise the great strides that have been made, and not to be discouraged when it may not be possible to check and edit the captions on every video produced.

Taking down video to avoid having to caption it disadvantages learners. The new learning and teaching landscape requires that students have access to the digital content they need in order to thrive. The best way forward is to be transparent about what you are doing.

Your accessibility statement is where you communicate how accessible your digital content is and what you are doing about non-compliant content.

Our guide on practical steps to meeting accessibility regulations explains how to approach statement writing.

Create department-level statements

If practice varies across your organisation, create department or school-level accessibility statements that accurately reflect the accessibility of content that staff and students will encounter.

If your school or department does not have the capacity to check and edit captions, state this under non-compliant content, or (if you are unable to provide captions due to the cost) disproportionate burden.

Is it a disproportionate burden?

The regulations provide for the situation where lack of resources will in some circumstances constrain the ability of an institution to comply fully with the accessibility requirement.

Considering the availability of built-in captioning technology for most online teaching platforms it is highly unlikely that providing captions for recorded learning sessions could be considered as an additional cost producing burden.

Captions that require substantial editing will involve a significant amount of staff resource to check and correct. This may result in a cost that your institution is unable to meet and you may decide you need to prioritise which video meets the required standard. If you do plan to claim disproportionate burden this must be done on the basis of cost. You should keep a record of your costings and decision making.

However, being unable to check and correct captions on all video should not prevent you captioning as much video as possible. Providing captions as accurately as possible remains the legal obligation.

Creative approaches from the sector

The UK further and higher education sector has found a range of creative solutions to providing captions in a sustainable way. The approach taken often reflects a provider’s budget, staff skills and capacity, and wider digital strategy. Here are some different pathways on the journey to better video accessibility:

• Hiring a team of staff and paid student interns to check and correct captions
• Using the Jisc licensing agreement for Verbit.ai to generate human-checked captions and transcripts
• Using a mix of different products, like Verbit.ai and Caption.Ed alongside some human checking on courses flagged as high priority (we’ll explain how to decide this below) and some automated captions on lower-risk content
• With experts in informatics, exploring the potential of AI and protected internal large language models to monitor accuracy and correct captions to a human standard
• Forming a ‘buddying’ group with a few other education providers at a similar stage of captioning provision, to share experiences of different tools and approaches

Optimising audio input - tips from our accessibility community

For many recordings, automatic speech recognition (ASR) will create useful captions. Some subject specific or technical terms will present more of a challenge to the software. However, the better the automated captions, the less editing will be required. 

Aiming for the best audio input you can achieve will optimise the performance of ASR, and it will be appreciated by all students who are listening to content. Here are some tips sourced from the Jisc accessibility community.

"Always use a mic. Wired is more reliable than Bluetooth." 

"Do a test recording before session to check the quality." 

"Having headset mics too close to your mouth picks up more speech distortion and sibilance. Try lowering or raising from mouth."

"Minimise background noise. This can be as simple as closing the door to your office."

"Use the full version of abbreviations and acronyms – this is good practice anyway, but ASR often struggles with these eg for WCAG (Web Content Accessibility Guidelines), many people say “wick-agg” which ASR cannot recognise, and it’s also unclear to newcomers to a meeting or subject what is being talked about talking about."

"Speak at a steady pace. Many students will appreciate this too eg non-native English speakers; those with language processing difficulties or difficulties with focusing. Encourage turn taking and manage behaviour like interrupting or people talking over one another."

Where to focus your efforts

Given the vast amount of video content produced, tertiary education providers often focus their captioning effort where it is most needed.

Some criteria for deciding where to focus your captioning efforts could include:

• Courses on which a deaf or hard of hearing student is enrolled
• Content that is high usage and essential for all students
• Content that will be used for a longer period
• Courses featuring specialist language that standard automated speech recognition will struggle with
• Courses where an inaccurate caption and resulting misunderstanding could lead to risk

If you are prioritising video content from courses on which deaf or hard of hearing students are enrolled, it is especially important to encourage early disclosure of a support need and have a robust system for communicating and implementing adjustments.

Getting started with the right technology

Each lecture capture system or video platform will have a different way to generate captions, so the process for you will depend on the technology you have access to in your institution.

Join the accessibility community to discover and discuss the various captioning technologies.

Making a difference to student experience

A continuous and creative approach to captioning across the sector is having a transformative impact on the experiences of students. 

Rachel O’Neill, senior lecturer at the University of Edinburgh, has observed an increase in positive experiences among deaf students. One deaf student she put in touch with Jisc told us, 

“The engineering department has been editing the automated captions after recording their lectures so that the subtitles are correct and word for word. I have been in touch with my course mates to ask how non-deaf students have found the experience of edited subtitles. Over half of the people on my course have found them helpful.”

Positive comments from non-deaf students on the course included: 

Captions are useful if the recording is not of good quality

Some people learn better through reading than listening, so subtitles are easier for learning

If a new phrase is used it is easy to understand as it is written

While the broader benefits of captioning are evident, for deaf or hard of hearing students it is essential to their learning. Feedback from a deaf student who relies on recorded lectures with corrected caption tells its own story:

“Personally, they have made so much difference. Prior to subtitles I was able to hear about 20% of the lecturers' words maximum. Now I can follow everything.”